`
`IN THE COURT OF COMMONPLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
`
`JEFFREY C. SCHEIDE,an Individual,
`
`CIVIL DIVISION
`
`Plaintiff,
`
`G.D. No. 01-6307
`
`vy.
`
`Issue No.
`
`ATLAS INDUSTRIES, INC., et al,
`
`ATLAS INDUSTRIES, INC.’S FACT
`WITNESS LIST
`
`Defendants.
`
`(Backlog Group 23 - Asbestos)
`
`Code:
`
`Filed on behalf of Defendant,
`Atlas Industries, Inc.
`
`Counsel of record for this party:
`
`Edmund L. Olszewski, Jr., Esq.
`Pa, LD. #25480
`
`Kelly Smith Dorenkamp, Esq.
`Pa. LD. #80140
`
`DICKIE, McCAMEY & CHILCOTE,P.C.
`Firm #067
`‘Two PPG Place, Suite 400
`Pittsburgh, PA 15222-5402
`(412) 281-7272
`
`JURY TRIAL DEMANDED
`
`
`
`G. D. No. 01-6307
`
`IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
`CIVIL DIVISION
`
`JEFFREY C. SCHEIDE,an Individual,
`
`Plaintiff,
`
`Vv.
`
`G.D. No. 01-6307
`
`ATLAS INDUSTRIES, INC., et al.,
`
`Defendants.
`
`ATLAS INDUSTRIES, INC.’S FACT WETNESS LIST
`
`AND NOW, comes the Defendant, Atlas Industries, Inc., by and through its attorneys,
`
`Dickie, McCamey & Chilcote, P.C. and pursuant to the Court’s Scheduling Order, sets forth the
`
`following Fact Witness List:
`
`A. RESERVATIONS
`
`1.
`
`2.
`
`3.
`
`4,
`
`Atlas Industries, Inc. may call any and al] witnesses listed in any Witness List or
`Disclosure of Witnesses filed on behalf of any party or in any supplemental
`Witness List or Supplemental Disclosure of Witnesses, including any medical,
`liability, opinion, condition, damage, expert, or records witnesses. By this
`imcorporation and subsequent incorporations, Atlas Industries, Inc. does not intend
`to incorporate by reference any proposed testimony which identifies any product
`utilized, sold, or supplied by Atlas Industries, Inc.
`
`Atlas Industries, Inc. reserves the right to call any witness to offer factual or
`opinion testimony for purposes of impeachmentor rebuttal, whether or not such a
`witness has been identified on the Witness List of any party.
`
`Atlas Industries, Inc. reserves the right to call any and all of the witnesses named
`in any of the pleadings of record, including, but not limited to Fact Witness Lists
`filed on behalf of the Plaintiff or other Defendants, Pre-Trial Statements filed on
`behalf of the Plaintiff or other Defendants, Plaintiff’s Responses to Defendants’
`Motions for Summary Judgment, Depositions, Answers to Interrogatories or
`Responses to Request for Admissions.
`
`Atlas Industries, Inc. reserves the right to cali any or all of Plaintiff’s treating,
`consulting and examining physicians which are now known or which later
`become known.
`
`
`
`G. D. No. 01-6307
`
`to call any impeachment or rebuttal
`Atlas Industries, Inc. reserves the right
`witnesses madenecessary by any witnesses’ testimonyat trial.
`
`Atlas Industries, Inc. reserves the right to call as witness, any photographer,
`subpoenaserver, or investigator of the Plaintiff or any Defendant.
`
`Atlas Industries, Inc. reserves the right to call as a witness, all parties and any
`present or former agent, servant, employee, representative or officer of any party.
`
`Each of the above inclusions and provisions pertains to each of the following
`categories of witnesses and should be read so as to be included in each category.
`
`B. LIABILITY WITNESSES
`
`Atlas Industries, Inc. may call any or all of the following persons as liability witnessesat
`
`the timeoftrial:
`
`9.
`
`10.
`
`All Plaintiffs, Plaintiffs’ family members or representatives.
`
`Ali co-workers of Plaintiff including, but not limited to, those identified in Fact
`Witness Lists filed on behalf of the Plaintiff or other Defendants, Pre-Trial
`Statements filed on behalf of the Plaintiff or other Defendants, Plaintiff’s
`Responses to Defendants’ Motions for Summary Judgment, Depositions, Answers
`to Interrogatories or Responses to Request for Admissions.
`
`il.
`
`Anyand ail employees or former employees or representatives of Atlas Industries,
`Inc., including, but not limited to:
`
`(a)
`
`William Bayer, President of Atlas Industries, Inc.
`530 Bell Avenue
`Carmegie, Pennsylvania
`
`12.
`
`Records Custodian of any or all of the following companies:
`
`13,
`
`14.
`
`15,
`
`(a)
`
`Any company at which Plaintiff worked and claims asbestos exposure.
`
`Record Custodian and/or representative of the various labor unions of which the
`Plaintiff was a member.
`
`Records Custodian
`Bureau of Workers’ Compensation
`
`Records Custodian
`Social Security Administration
`Bureau of Disability Insurance
`Baltimore, MD 21235
`
`
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`
`G. D. No. 01-6307
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that a true and correct copy of the foregoing Fact Witness List was
`
`mailed to Plaintiff's counsel of record this 6th day of September, 2007 by United States First
`
`Class Mail, postage prepaid and notice of the filing of same was served via electronic mailto all
`
`other counsel of record.
`
` EamonL. Olszewski, Jr., Esq.
`
`Kelly Smith Dorenkamp, Esq.
`
`Attorneys for Defendant,
`Atlas Industries, Inc.
`
`
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